MAP Application

Where to file MAP requests?

• MAP requested by the Indonesian Taxpayer shall be submitted to the Director General of Taxes through District Tax Office where the Indonesian Taxpayer is registered.
• MAP requested by Indonesian Citizen (for non-discrimination issues) or Competent Authority of the Tax Treaty Partner shall be submitted to Director General of Taxes through Director of International Taxation.

What are the requirements?

• MAP requested by the Applicant shall satisfy the following requirements:

1. the request shall be written in Bahasa Indonesia;
2. the request shall describe the actions considered not in accordance with the provision of tax treaty according to the Applicant (Indonesian Taxpayer or Indonesian Citizen);
3. the request shall be submitted within the timeframe set out in the tax treaty, otherwise within 3 years at the latest.
4. the request shall be signed by the Applicant or its representatives as referred to in Article 32 paragraph (1) of Law on General Provisions and Tax Procedures
5. the request shall be attached with the following documents:

1. certificate of domicile or any other document con3/18/2025taining the identity of the Taxpayer of treaty partner related to MAP request on the issue of paragraph 8a. (double taxation) and 8b. (withholding tax) above,
2. lists of information and/or evidence pointing out that there is taxation not in accordance with the treaty's provision,
3. statement letter declaring the willingness of the Applicant to provide information completely and timely.

• Please be advised that the MAP request form is provided in Annex of PMK-172/2023.

The timeline for MAP Application

• MAP request shall be submitted within the time limit as stipulated in the tax treaty. Please be advised to check the pertinent tax treaty since the provisions regarding the time limit may vary for each tax treaty. However, if the tax treaty doesn't set out the timeframe, MAP request shall be submitted within three years, started from:

1. the date of Notice of Tax Assessment;
2. the date of payment or withholding tax slip;

the date of taxation not in accordance with the provision of tax treaty.